TXX-6388, Forwards Response to Notice of Violation Item H from Insp Rept 50-446/86-02.Corrective Actions:All Cases Where CB&I Did Not Accept Original Radiograph & Did Not Classify Any Addl Work as Repair Reviewed
| ML20209C916 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/24/1987 |
| From: | Counsil W, Keeley G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-6388, NUDOCS 8704290110 | |
| Download: ML20209C916 (6) | |
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Log # TXX-6388 4
MM File # 10130 d
IR 86-03
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IR 86-02
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Ref # 10CFR2.201 1llELEC7RIC i
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William G. Counsil 2
Executive Vice Presskn' April 24, 19'87 f
U. S. Nuclear Resulatory Commission Attn: Document Control Desk Washington, D.C.
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SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 tND 50-446 INSPECTION REPORT NOS. 50-445/86-03 AND 50-446/86-02 RESPONSE TO NOV ITEM H (50-446/8602-V-10)
Gentlemen:
Attached is our response to NOV Item H (50-446/8602-V-10). The response was due on February 20,1987;. towever, due to the nature of the item, extens' ions were requested and granted to March 6, 1987, April 10, 1987 and to April 24,C 1987,' The attachment also includes information on the CB&I practice of
" pickup and reshoot."
Very truly yours, W'. G. Co sil M!
By:
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G. S. Keeley a /-
Manager,NuclearLice[ sing i
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c - Mr. E. H. Johnson - Region IV Mr. D. L. Kelley, RI - Region IV l
Mr. H. S. Phillips, RI - Region IV i
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Attachment 4gb.
TXX-6388 9
April 24, 1987 Page 1 of 4 NOTICE OF VIOLATION ITEM H (446/8602-V-10)
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Criterion IX of Appendix B to 10 CFR Part 50 states, in part, " Measures shall be established to assure that special processes, including welding... and nondestructive testing, are controlled in accordance with applicable code %;
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standards, specifications, criteria, and other special requirements."
Section CC-5521.1.1 of Code ACI-359, states, in part, "If the 12-in.
Radiograph in the 50-ft. long increment of weld does not meet the acceptance
- i standards...the remaining portion of the 50-ft. increment of this weld shall be radiographed."
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j Contrary to the above, the required radiography of the remaining portion of a 50' increment of weld was not performed even though one of the two second 12;,
radiographs (No. 146T2) at seam P84 in the Unit 2 containment liner did notJ meet the acceptance standards.
RESPONSE TO ITEM H (446/8602-V-10) j We deny the alleged specific violation but admit to the related violations resulting from our investigation of the alleged specific violation for the reasons that follow.
j The film (146T2) referenced in the finding was originally evaluated by the CB&I radiographic film interpreter who determined that the area needed to be-i re-radiographed to clarify an area of the film. The area of interest was re-
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radiographed (146T2 RSI) with the radiographic source centered over the area
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of interest, not over the entire 12-inch length of weld contained in the i
original (146T2). This was done to increase the-radiographic sensitivity in the area of interest and enable the CB&I interpreter to clearly evaluate the indication in the area of interest. The film 146T2 as clarified by 146T2 RS1, was interpreted to be acceptable by both a CB&I and a Brown & Roothvel III examiner.
Subsequent to the NRC expressing concerns, four other personnel who de.
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independent from the original reviewers have evaluated the film. ' All'of these.
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personnel are currently certified as Level III RT by their respective f
employers, and all four interpreters have accepted the film (146T2 RSI) fc0 this area.
Based on the initial evaluations and the substantiation of those evaluations by our independent reviewers, the film in question (146T2 as clarified by 146T2 RSI) meets the applicable acceptance standards; therefore, i
j additional r6diography is not required.
To further assure that no defects are present in the area, the paint was removed and the area in question was 4
examined by ultrasonic testing (UT). This additional testing also confirmed an absence of rejectable indications. Since the 12-inch radiograph in question was determined to be acceptable, radiography of the remaining portion i
of the 50' increment of the weld was not required.
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Although we do not agree that the alleged specific violation occurred, our' i
review of the alleged specific violation did reveal the following jelated violations: (1) eleven (11) instances where the description of the surface conditioning indicated on the CB&I RT Report was not a complete iepresentation of the surface conditioning that occurred, and (2) one (1) instance where a l
Code-rejectable indication was repaired without performing required NDE.
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. Attachment TXX-6388 lk April 24, 1987 Page 2 of 4 i
f RESPONSE TO ITEM H (446/8602-V-10) CONT'D j
1.
Reason for the Related Violation Regarding the incomplete records:
Either the Welding /QA Supervisor failed to indicate on the temporary record the surface conditioning that actually occurred, or the Welding /QA j.
Supervisor failed to detect that the method of surface conditioning 4
4 indicated on the temporary record was different than that indicated on the
Regarding the lack of performance of. required NDE:
i While performing radiography on the horizontal girth seam between the third and fourth rings (Seam Number 3A), a Code-rejectable linear indication appeared in the film for film Number 13-14. This indication was not in the weld being radiographed, rather in the intersecting vertical weld (Seam Number 3C). The repair was erroneously. described on
!s the RT Report as " Surface Pickup Made.'" A review of the records indicates j
that no PT or MT of the excavated area was performed as required.
2.
Corrective Steos Taken and Results Achieved i
Regarding'the incomplete records:
bi We have reviewed all cases where CB&I did not accept the original i
radiograph and did not classify any additional work as " repair".
This review was of all cases where original radiography was rejected for
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density, insufficient grinqing, pickup and reshoot, reshoot at customer 1,.
request, etc. neccasitatira additional radiography. This review g encompassed 111 areas fn Unit I and 25 areas in Unit 2.
The review g
l revealed instances where it appears that filler metal was deposited yet g the RT Report indicates.only grinding was performed. This matter is l
.i without technical significance because the surface conditioning was finally e.ccepted bothrvisually and by RT examination. Deficiency Report (DR) C87-2129 was initiated to document our corrective actions. No further corrective action is required.
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Regardingthelack[fperformanceofrequiredNDE:
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i The purpose of the NDE (MT or PT) of the excavated area is to assure that the defect is entirely removed prior to rewelding the cavity, thereby j
j precluding additional, repair of the same defect.
In this case, it is clear in the subsequent. radiograph that the linear indication was entirely removed. To ensure that this was an isolated instance, as stated above we have reviewed all cases where original radiography was rejected without j
classifying additional work as " repair" and'found no other cases where j
Code-rejeccable indications were removed without performance of NDE of the excavated cavity (before rewelding. Nonconformance Report CM87-5551 was initiated to document our corrective actions. No further corrective action 3prequired.
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Attachment TXX-6388 April 24, 1987 Page 3 of 4 RESPONSE TO ITEM H (446/8602-V-10) CONT'D 3.
Corrective Steos Which Will be Taken to Avoid Further Violations The installation of the Unit I and 2 containment liners is complete; i
j therefore, no preventive actions are required.
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Date of Full Comoliance Full compliance has been achieved.
I Sunolemental Information on a Related Issue Although not noted as an issue in the NRC Inspection Report, the details of l
the report appear to identify an open item involving the CB&I practice of j
" pickup and reshoot." The following is submitted to provide clarification of.
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that practice.
Radiographic examination requirements for weld seams of the containment liner are specified by Gibbs and Hill Specification 2323-SS-14,
" Containment Steel Liner," and Regulatory Guide 1.19.
" Nondestructive Examination of Primary Containment Liner Welds." These requirements provide assurance of a uniform quality level of welds by assuring continued satisfactory welder performance.
I The area originally radiographed as area 146 was rejected for slag and unacceptable porosity. Two tracer areas,146T1 and 146T2, were subsequently radiographed as a result of the original rejected radiograph.
146T1 was determined.to be acceptable.
146T2 was determined to be unacceptable and 4
marked " pickup and reshoot"; however, the RT report does not note any weld defect as the reason for rejection, e.g., porosity, slag, linear indication,-
etc. The additional surface conditioning (i.e., a pickup) of the weld was necessary to properly interpret the film, and to assure that the area of high density in the film was neither a rejectable indication-itself, nor masked a rejectable indication.
ASME Boiler and Pressure Vessel Code interpretation V-77-05 clarifies that surface defects such as undercut are not criteria for rejecting a radiograph.
These defects may, however, mask or hide an internal weld defect. To remove doubt of hidden defects, CB&I's practice was to eliminate the undercut condition by performing " pickup." CB&I defines a " pickup" as a surface weld on defective material or weld metal. The weld pass fills in low surface areas such as weld undercut, scars or similar surface conditions. The optimal time to identify &nd perform such surface conditioning is prior to the original radiograph, thereby obviating subsequent radiography to clarify abrupt density changes in the film.
The identification of the welder who performed the pickup is identified on the i
RT report for the reshoot. The welding procedure used is specified on the record drawing. The process of surface conditioning (pickup / grinding),
including visual inspection of the finished surface, is controlled on temporary records.
The records are reviewed by the Welding /QA Supervisor to assure all required work is complete and accepted prior to his signing the
" Complete Checks and Examinations of Joint Completed and Accepted" column on the Record Drawing.
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Attachment TXX-6388 April 24, 1987 Page 4 of 4 RESPONSE TO ITEM H (446/8602-V-10) CONT'O To assure that CB&I's practice of pickup and reshoot was properly applied (i.e., the term " pickup" was not used in lieu of " repair" to avoid additional required NDE), we have reviewed all cases where the original radiograph was rejected and subsequent work was not termed repair. (See discussion above).
We have concluded as a result of this review that no cases exist where a volumetric repair of a Code rejectable indication was made without subsequent radiography being performed (for reasons other than the rejection of the area in question) of the entire interval of weld. Therefore, any concern regarding any incorrect classification of " repair" or " pickup" is rendered moot.
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